1 comments
April 17, 2020
Sylvia Rosa-Casanova
State Council of Higher Education for Virginia
101 N. 14 Street
Richmond, 23219
Re: Regulations Governing the Certification of Certain Institutions to Confer Degrees, Diplomas, and Certificates (8VAC 40-31)
Dear Ms. Rosa-Casanova:
On behalf of the student servicemembers, veterans, their family members and survivors that we represent, we thank you for the opportunity to comment on the enrollment contracts used by certain private and out-of-state institutions.
Veterans Education Success has found that enrollment contracts are increasingly being used by certain postsecondary institutions as ways to limit the rights of the students that we serve. Restrictive clauses are often an attempt by institutions to provide legal cover for unscrupulous marketing and lower-quality education.
The state of Virginia should not allow students to sign enrollment contracts that use any of the following:
Virginia should be on the lookout for and refuse to certify any institution that uses clauses in enrollment contracts that restrict the rights of students. Schools are increasingly using these clauses to cover up behavior that hurts students. The state of Virginia has an interest in making sure that its residents are getting what they pay for when it comes to higher education.
Additionally, enrollment agreement renewals should be required if either the student OR the institution makes changes to the program or enrollment. In the event that an institution delays a student’s start date or changes the program of enrollment, a new enrollment agreement must be completed. Postsecondary institutions regularly make changes that affect students, without the student’s permission or knowledge, and enrollment agreements should reflect those changes.
A skyrocketing national unemployment rate portends millions of students, and minimally thousands of Virginians, returning to school to burnish their credentials. Virginia has an interest in making sure that they reenter the workforce as successful taxpayers. One of the most efficient ways to do so is to prevent the use of these restrictive clauses in enrollment contracts.
Sincerely,
Michael Saunders,
Director of Military and Consumer Policy
&
Ramond Curtis,
State Policy Manager
Veterans Education Success